Please use this identifier to cite or link to this item:
Title: Revisiting Identification Issues in GDPR ‘Right Of Access’ Policies: A Technical and Longitudinal Analysis
Authors: DI MARTINO, Mariano 
MEERS, Isaac 
QUAX, Peter 
Issue Date: 2022
Publisher: Sciendo
Source: Proceedings on Privacy Enhancing Technologies, 2022 (2) , p. 95 -113
Abstract: Several data protection regulations permit individuals to request all personal information that an organization holds about them by utilizing Subject Access Requests (SARs). Prior work has observed the identification process of such requests, demonstrating weak policies that are vulnerable to potential data breaches. In this paper, we analyze and compare prior work in terms of methodologies, requested identification credentials and threat models in the context of privacy and cybersecurity. Furthermore, we have devised a longitudinal study in which we examine the impact of responsible disclosures by re-evaluating the SAR authentica-tion processes of 40 organizations after they had two years to improve their policies. Here, we demonstrate that 53% of the previously vulnerable organizations have not corrected their policy and an additional 27% of previously non-vulnerable organizations have potentially weakened their policies instead of improving them, thus leaking sensitive personal information to potential adversaries. To better understand state-of-the-art SAR policies, we interviewed several Data Protection Officers and explored the reasoning behind their processes from a viewpoint in the industry and gained insights about potential criminal abuse of weak SAR policies. Finally, we propose several technical modifications to SAR policies that reduce privacy and security risks of data controllers.
Keywords: subject access request;GDPR policies;au- thentication issues;social engineering
Document URI:
e-ISSN: 2299-0984
DOI: 10.2478/popets-2022-0037
Category: A2
Type: Journal Contribution
Appears in Collections:Research publications

Files in This Item:
File Description SizeFormat 
10.2478_popets-2022-0037.pdfPublished version534.66 kBAdobe PDFView/Open
Show full item record

Page view(s)

checked on Sep 7, 2022


checked on Sep 7, 2022

Google ScholarTM



Items in DSpace are protected by copyright, with all rights reserved, unless otherwise indicated.